EFF Call for sign-ons: ISPs, networking companies and engineers opposed to FCC privacy repeal

Dan Hollis goemon at sasami.anime.net
Wed Mar 29 21:53:11 UTC 2017

Why aren't _ALL_ consumer privacy regulations managed by the FTC?

Why is the FCC needed here?


On Wed, 29 Mar 2017, Mark Radabaugh wrote:

>> On Mar 29, 2017, at 9:59 AM, Joe Loiacono <jloiacon at csc.com> wrote:
>> Lowering barriers to entry is where the next political focus should be.
>> Joe Loiacono
> And there you have much of the problem with this privacy bill.
> Read the actual Report and Order:  https://apps.fcc.gov/edocs_public/attachmatch/FCC-16-148A1.pdf <https://apps.fcc.gov/edocs_public/attachmatch/FCC-16-148A1.pdf>
> 219 pages
> You want to start a competitive ISP these days?   Make sure you:
> Incorporate your business
> Obtain Liability, Workers Comp, Unemployment, Auto Insurance
> Comply with the FCC Privacy Act (short reading, requires considerable investment in tracking opt in, opt out, privacy policies)
> File the mandatory FCC 477 filings twice a year with detailed information on the geolocation of all of your customers and service area.
> If offering VoIP service file your 499-A and Quarterly 499-Q’s with the FCC
> Draft your “Open Internet Disclosure Statement”, pay a FCC lawyer a couple grand to renew it, make sure it’s prominent on your website
> Build your website
> Obtain bandwidth and IP, fill out your ARIN information.
> Make up your “Consumer Label” for Broadband: https://www.fcc.gov/consumers/guides/consumer-labels-broadband-services <https://www.fcc.gov/consumers/guides/consumer-labels-broadband-services>  (probably need a lawyer for this too..)
> Pay the lawyer to write your “Terms of Service” so that you have at least some chance of surviving the lawsuits
> Implement your CALEA plan and file that paperwork with the FBI so they can find you
> Register with the Copyright office so that you can deal with DMCA notices.
> Establish your copyright policy and procedures.  Have your lawyer review it.
> Make sure you comply with 18 USC 2258A regarding reporting and registration for kiddie porn, train your employees
> Make sure you have a CPNI policy, training, and report to the FCC yearly
> Implement and file your Section 255 “Disability Rights” policy and make sure you file yearly with the FCC your information
> Slap up a Ubiquiti access point and you can now make millions of dollars in short order.
> I’m sure I forgot a few things like “build your network”, but that’s simple.
> Mark

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